Employers regularly confirm their understanding of properly completing the Occupational Safety and Health Administration (OSHA) 300 Log following a recordable injury during the year; however, some fail to realize they also have an obligation at year end to review the log and complete the Form 300A summary form. Your end of year review and completion of the summary form provide an excellent opportunity to address any safety deficiencies. It may also be an opportunity to review policies and procedures beyond OSHA and safety requirements. It is never a bad time to implement new policies to bring your company into compliance.
The regulations require that you: (1) total the columns of the OSHA 300 Log; (2) enter the calendar year covered, the company’s name, establishment name, establishment address, annual average number of employees covered by the Form 300 Log, and the total hours worked by all employees covered by the Form 300 Log. 29 C.F.R. §1904.32(b). If you are not using the prescribed OSHA 300A summary form, you must include the employee access and employer penalty statements found on the form. This summary must be certified and posted no later than February 1 of the year following the year covered by the records and stay posted until April 30. Compliance is important as OSHA can cite an employer for its failure to post the Form 300A as required. It is also likely that failure to comply with the summary posting requirement may signal other non-compliance to an investigator. In many cases, following rules such as the posting requirement coupled with the initial presentation of organized and completed records will go a long way towards a smooth on-site inspection.
It is important that when reviewing the Form 300 Log for certification, employers should note and address any areas of concentration of injuries or areas of serious injuries. Numerous injuries may suggest that a compliance deficiency is present and should be addressed. If an employer is unsure as to the requirements of the regulations or whether their work place is compliance, they should consult with their employment counsel.
By: Justin A. Morocco